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§ 105

Deep v. Danaher

Ruling
Bankruptcy court did not abuse discretion in enjoining debtor from filing pleadings without leave of court.
Procedural posture

Plaintiff brought an action against defendants, two chapter 7 trustees and two others. At issue in plaintiff's appeal was whether the bankruptcy court abused its discretion by acting pursuant to 11 U.S.C.S. § 105 to enjoin him from filing further pleadings in the bankruptcy court without obtaining prior leave of the bankruptcy court.

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Consumer opinion summary, case decided on August 18, 2008 , LexisNexis #0908-062

Scrivner v. Mashburn (In re Scrivner)

Ruling
Bankruptcy court did not have authority to approve surcharge for postpetition distribution of television revenues.
Procedural posture

Appellants, debtors who disclosed in their petition but did not claim as exempt an interest in television program revenues, appealed the judgment of the Bankruptcy Appellate Panel for the U.S. Court of Appeals for the Tenth Circuit (BAP), affirming a bankruptcy court's authorization post-discharge of a surcharge for post-petition distributions of the revenues, and the BAP's refusal to decide whether the debtors' distributions were exempt.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on August 08, 2008 , LexisNexis #0908-018

Seaver v. Burwell Family L.P. (In re Burwell)

Ruling
Bankruptcy court properly granted trustee's motion for turnover of assets of entities deemed to be debtor's alter egos used to defraud creditors.
Procedural posture

Two entities, a limited partnership and a limited liability company both associated with the debtor, appealed from an order of the United States Bankruptcy Court for the District of Minnesota, that entered a default judgment against each entity finding that each was the alter ego of the individual debtor, and which ordered the assets of the entities to be included in the bankruptcy estate.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on August 07, 2008 , LexisNexis #0808-106

In re Crink

Ruling
Administrator's motion to strike debtors' Schedule I and redetermine debtors' monthly income denied as without authorization.
Procedural posture

The United States Bankruptcy Administrator (BA) filed a motion pursuant to 11 U.S.C.S. § 105 to strike chapter 7 debtors' Schedule I and set a new time period for determining the debtors' current monthly income.

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Consumer opinion summary, case decided on July 31, 2008 , LexisNexis #1008-106

In re Luedtke

Ruling
Creditor ordered to remove negative report to credit agency or face sanctions.
Procedural posture

The debtor had secured automobile loan from creditor, a credit union. As the completion of her chapter 13 plan neared, she alleged that the creditor had falsely reported her loan account as being delinquent in the pre-confirmation amount of the debt, and the debtor moved to require the creditor to accurately reflect her postpetition plan payments as current on the credit report, and for sanctions pursuant to 11 U.S.C.S. § 105.

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Consumer opinion summary, case decided on July 31, 2008 , LexisNexis #0808-131

In re Eilderts

Ruling
Case dismissed due to debtors' failure to turn over economic stimulus rebates to the estate in accordance with confirmation order.
Procedural posture

The debtors applied for permission to retain their economic stimulus rebate payment from the Internal Revenue Service (IRS) in order to buy a replacement vehicle. The trustee objected.

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Consumer opinion summary, case decided on June 05, 2008 , LexisNexis #0708-036

Go West Entertainment Inc. v. New York State Liquor Auth. (In re Go West Entertainment Inc.)

Ruling
Court declined to stay revocation of liquor license that was crucial to debtor's ability to conduct business.
Procedural posture

Plaintiff debtor filed a motion for a preliminary injunction staying the effectiveness of the revocation of the debtor's liquor license by defendant New York State Liquor Authority (SLA). The debtor sought a stay pending its appeal in the state courts of the SLA's revocation of the license.

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Commercial opinion summary, case decided on May 14, 2008 , LexisNexis #0608-106

In re Potter

Ruling
Creditor sanctioned for prosecuting state court action against another creditor in violation of stay.
Procedural posture

A bank filed a motion requesting the court to enter sanctions for violations of the automatic stay against another creditor under 11 U.S.C.S. § 105 based on the creditor's continued prosecution of a state court action.

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Consumer opinion summary, case decided on April 16, 2008 , LexisNexis #0608-026

In re Blanchard

Ruling
Debtors' attorney held in contempt and barred from practice before the bankruptcy court due to failure to comply with court orders.
Procedural posture

After an attorney who had been representing a chapter 7 debtor failed to comply with a court order directing her to file an itemized statement of fees and expenses as well as time records relating to debtor's case and after she failed to appear at a subsequent hearing on the same issue, the court notified all parties that it would consider the imposition of sanctions at a new hearing, for which notice was given.

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Consumer opinion summary, case decided on April 14, 2008 , LexisNexis #0508-071

56 Assoc. v. Diorio

Ruling
Deceased debtor's co-owners sanctioned for improper conduct in connection with trustee's efforts to sell property.
Procedural posture

Appellants, co-owners and tenants-in-common in real estate with a deceased debtor whose estate was bankrupt, sought review of orders of the U.S. Bankruptcy Court for the District of Rhode Island authorizing appellee trustee to sell the building and the land on which it stood in its entirety. Appellants also raised other objections to the proceedings below.

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Consumer opinion summary, case decided on January 30, 2008 , LexisNexis #0208-091